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Office of Sponsored Programs (OSP)

Technology Control Plan

Definition

A Technology Control Plan (TCP) is an internal UW compliance document prepared by the Principal Investigator and approved by the Office of Sponsored Programs. It states the type of export-controlled information associated with a research project, measures to be taken by the PI to ensure access to the export-controlled information is managed, and signed by the PI.

Purpose

A TCP is required when:

  • A research project involves the receipt of export-controlled information from an outside party, such as via a nondisclosure agreement or sponsored research agreement.
  • A research project is not considered fundamental research and the research results may contain export-controlled information. A project that is restricted, proprietary, or classified is not fundamental research.

In order to prevent a deemed export violation, a TCP sets out necessary procedures to manage access to export-controlled information, consistent with the Export Administration Regulations (EAR) and the International Traffic in Arms Regulations (ITAR). A TCP needs to be completed and approved prior to handling export-controlled information associated with a research project. In some cases, this may be prior to the project start date. For receipt of export-controlled information not associated with a research project, please see Certification for the Handling and Use of Export-Controlled Information.

Template

If it is determined that a project requires a TCP, the PI must use the UW TCP template as a basis for establishing a control plan. Assistance from Carol Rhodes, UW Export Control Specialist (ECS), is available. She can be reached at (206) 543-2139 or carhodes@u.washington.edu.

Upon completion of the TCP, the PI must sign and furnish a copy to the ECS and the Department Grants Manager or Administrator. Upon approval of the TCP by the Office of Sponsored Programs, the PI may proceed with the handling of export-controlled information.

Guidelines

A TCP requires detailed explanation of security measures to manage export-controlled information. The procedures that each department and PI undertake may vary depending on the nature of the information and the location of the PI’s research work. Below, please find some University guidelines and standards as a reference for implementing your TCP.